Jaguar Critical Habitat and Recovery Plan

Jaguar Recovery Plan

Dennis Parker’s comments and attachments submitted on behalf of SACPA et al. on March 18, 2017 on the Draft Jaguar Recovery Plan (Click to view SACPA’s comments)

Jaguar Critical Habitat

This page was last updated March 18, 2017.

We thank Dennis Parker for his excellent work and we thank every person and organization who contributed their hard earned dollars to fund his very important work.

The US Fish and Wildlife Service (Service) has designated more than 3/4 million acres of Arizona and New Mexico as critical habitat for jaguars, in essence determining critical habitat is “essential” to prevent a range-wide extinction of the entire jaguar species.


 Dennis Parker’s comments submitted July 30, 2013

Comments and research submitted October 19, 2012 by Dennis Parker on behalf of SACPA in response to proposed Jaguar critical habitat designation.

April 2012 Jaguar Recovery Plan Response – submitted by Dennis Parker on behalf of Pima NRCD

 Dennis Parker’s September 23, 2010 comments and research on the Prudency decision for Jaguar Critical Habitat

Attachments to September 23 comments.

Dennis Parker’s March 15, 2010 comments on the Prudency of a Critical Habitat Designation for the Jaguar in Arizona and New Mexico

Key Issues:

  • Dozens of jaguars were historically imported into Arizona and New Mexico for sport hunting. Strong evidence indicates the female jaguar killed in 1963 and the male killed in 1964 were originally imported for sport hunting but may have been released in order to avoid criminal charges.
  • All models of jaguar habitat cited in the Federal Register relied on a database including unreliable reports of jaguars, some of which were imported for sport hunting. In addition, none of the authors in the cited literature did proper diligence on their citations, preferring to cite citations to citations. As a result, as exposed in the attachments SACPA submitted October 19, 2012, many of the jaguar records used in their models were woefully inaccurate or unverifiable. Many were actually duplicated, meaning single jaguars were counted multiple times.
  • Literature cited in the Federal Register contain charts purportedly showing jaguar “demise.” All such charts politically omit data prior to 1900, when jaguar occurrences were as rare as they are today, if not more so, in Arizona and New Mexico.
  • The Boydston and Lopez-Gonzales paper upon which the USFWS determined jaguar critical habitat is “prudent” was not peer-reviewed, does not present data, hence is not verifiable and therefore does not measure up to ESA requirement for the “best available science” because it is not science. 
  • The Service relied on historical records that it knows are unverifiable and unreliable, including documents that it knows are entirely inaccurate hearsay.
  • The Service’s designation of critical habitat relied heavily on “data” that was collected by a researcher whom it knows employed unethical methods including illegal sexual scent baiting and illegal snaring that a) killed not just one but several jaguars, b) were not mentioned in his research methodology and c) violated the ESA. The researcher pleaded guilty to violating the Endangered Species Act (ESA) and was prohibited from practicing biology in the United States for five years.
  • The Service illegally twisted the ESA term “occupied” to mean “occurrence.”
  • The Service illegally redefined “at the time of listing” to span 50 years.
  • The Service relied on historical records that it knows are unverifiable and unreliable, including documents that it know are entirely inaccurate hearsay.
  • The boundaries of the designated critical habitat are not clearly identified on a topographic map, have no legal description, and therefore violate the ESA. A private property owner within the designated critical habitat has no way to determine exactly where critical habitat begins or ends on their own property.
  • There is no documented record of any naturally occurring female jaguar in New Mexico, ever.
  • There is no evidence of any historical breeding populations of jaguars in New Mexico or Arizona.
  • The rule may adversely impact border security,  water rights, water distribution, water infrastructure maintenance, motorized travel, mining, energy transmission projects, the local tax base, rural school budgets, property values, vegetation management, prescribed fires, and potentially even harm other endangered species (as the ESA pits one species against another). More importantly, it will provide lucrative new avenues for the environmental litigation industry to strip you of  your rights, property and freedom.

Click here to view a background primer on the rule.


Click on the Figure below to enlarge it.


The Northern Recovery Unit covers than 7 million acres in the USA. The USFWS is now proposing 858,137 acres for a Critical Habitat designation.